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Elements of an Emergency Plan

OSHA requires specific training for emergency response, as outlined in CFR 1926.65 paragraph (q). This paragraph states that training must address (among many other topics) the need for and use of personal protective equipment, including respirators. Employers should take this and the following elements into consideration when developing an emergency plan that accurately includes PPE:

  • The decontamination procedures to be used (and if these decontamination procedures require PPE)
  • Preplanning activities for hazardous substance incidents, including the emergency response plan (and if these activities require PPE)
  • Company standard operating procedures (SOPs) for hazardous substance emergency responses (and if PPE is needed, given the identified and potential hazards on site)

OSHA notes that "hands-on training should be stressed whenever possible. Critiques done after an incident which include an evaluation of what worked and what did not and how the incident could be better handled the next time may be counted as training time." Employers should remember that PPE as related to emergency plans is an ongoing process of selection, use, and maintenance.

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